Governance Briefing — August 7, 2025

Executive briefing: The UK Financial Conduct Authority’s Policy Statement PS23/16 activates entity-level Sustainability Disclosure Requirements (SDR) for in-scope asset managers for financial years starting on or after 2 December 2024. That means FY2025 reports—covering governance, strategy, risk management, and metrics—must be published within four months of the period end and tagged to the FCA template by 2 December 2025.

Key governance checkpoints

Board oversight. Document how the board evaluates sustainability factors in investment processes and risk appetite, aligning with PS23/16 Annex 2 requirements.
Metric definition. Lock in greenhouse gas, stewardship, and diversity metrics, including calculation methodologies and data sources, ensuring consistency with existing TCFD or ISSB reporting.
Control attestations. Establish first- and second-line review procedures and internal audit coverage so the senior management function can sign off on SDR disclosures.

Operational priorities

Data lineage. Trace each disclosed metric back to custodians, benchmarks, or climate data vendors and record data quality thresholds to defend assurance testing.
Label alignment. Confirm fund-level labels, sustainability objectives, and entity-level narratives align, particularly where products use the Sustainability Focus or Improvers labels.
Publication workflows. Prepare HTML and PDF outputs, accessibility checks, and submission packages for the FCA reporting portal ahead of the December deadline.

Enablement moves

Integrate SDR reporting requirements into enterprise disclosure calendars alongside CSRD, SEC climate, and ISSB filings.
Engage external assurance providers now to scope limited assurance for the 2025 cycle, even though it remains voluntary.

Sources

Zeph Tech unifies SDR data pipelines, governance attestations, and publication workflows so asset managers avoid December reporting crunches.